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PS19/20 Final Rules:Optimising the SM&CR

Final Rules: PS19/20 Optimising the SM&CR

29th July 2019

The FCA has now published a Policy Statement PS19/20 in relation to their Consultation CP19/4: Optimising the Senior Managers & Certification Regime (SM&CR).

Detailing the feedback and final rules, the FCA notes within PS19/20 that they have implemented the proposed changes to the existing rules as consulted upon.

The main changes to SM&CR as now detailed include:

SM&CR: Client Dealing Function

Additionally the regulator has amended the scope of the Client Dealing Function as consulted, advising that the amended rule has been drafted in such a way that provides firms with the flexibility to exercise judgment over whether a role requires certification.

In this regards, the relevant factors that a Firm would need to consider in assessing an individual’s role are:

To read the Policy Statement and final rules issued by the FCA, click here.

SM&CR will commence for all solo-regulated firms come 9th December 2019, this includes Claims Management Companies that are regulated by the FCA. However, still to be announced, will be the SM&CR commencement date for Benchmark Administrators. The FCA have informed they have requested and agreed with HM Treasury for a later SM&CR commencement date for benchmark administrators so that they may carry out a dedicated sector-specific consultation before making final rules for this sector and therefore this implementation date is still to be announced.

SM&CR Practical Support:

If you are preparing your firm for the extension of the SM&CR regime and need any advice or support, our experienced regulatory consultants would be happy to offer their assistance and practical support. Just drop our friendly team a line to discuss how we can help.

SM&CR Related Reading:

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SM&CR for Solo-Regulated Firms

The Senior Managers & certification Regime will apply to Solo-Regulated Firms from December 2019.




SM&CR Key Dates